Joint Core Strategy - Proposed Main Modifications

Appropriate Assessment and conclusions

5 Appropriate Assessment and conclusions

5.1 Screening of the Proposed Main Modifications to the JCS was unable to rule out likely significant effects on Rutland Water SPA and Ramsar site and on Upper Nene Valley Gravel Pits SPA and Ramsar site. It was therefore necessary to proceed to the more detailed Appropriate Assessment in this Chapter which sets out for each of these European sites:

European site information, being a summary of the designated features of interest, the factors required to support their integrity and the types of potential effect from the JCS to which these designated features are vulnerable (full information on these is available in the HRA Report for the Pre-Submission JCS to which this report is an addendum).
A table detailing for each type of potential effect:
- the previously assessed effects of the Proposed Changes JCS prior to mitigation;
- mitigation included within the JCS;
- in-combination effects from other plans and projects;
- conclusions of the HRA for the Pre-Submission JCS, as amended by the HRA Addendum for the Proposed Changes, on the effects of the JCS alone or in-combination with other plans or projects on European site integrity and any recommendation for further avoidance or mitigation; and .
- the effects of the Proposed Main Modifications to the JCS alone or in-combination with other plans or projects on European site integrity.

5.2 This is followed by a summary of the overall conclusions of the HRA of the Proposed Main Modifications.

Rutland water SPA and Ramsar site

European site information

5.3 Rutland Water is situated approximately 24 km to the north east of the Plan area and is the primary water source for West Northamptonshire. It has dual designation as an SPA and a Ramsar site, both of which listings are for the outstanding congregations of wintering waterfowl present on the site.

5.4 The integrity of the European site depends on maintenance of: water levels and water quality appropriate for the species concerned; disturbance-free areas; diversity and structure of aquatic vegetation as a food source and nesting habitat; diversity of invertebrate food species; and limits to artificial stocking for angling.

5.5 The types of potential adverse effect on this site identified by previous stages of HRA were related to water supply and water levels and consequential effects on water quality and bird disturbance.

Appropriate assessment of Proposed Main Modifications to JCS

5.6 The Appropriate Assessment of the Proposed Main Modifications to the JCS is set out in the final column of Table 5.1. It builds on the previous HRA conclusions (set out in the HRA of the Pre- Submission Core Strategy, as amended by the HRA Addendum accompanying the Proposed Changes Core Strategy) which are summarised in the first four columns of the table.

Table 5.1 Appropriate Assessment of the effects of the JCS on Rutland Water SPA and Ramsar Site

Potential effect of the Proposed Changes JCS prior to mitigation

Mitigation included within the JCS

In-combination effects

HRA conclusion on effects of Proposed Changes JCS

Effects of the Proposed Main Modifications to the JCS, alone or in- combination

Water supply and water levels

The HRA of the Emergent JCS originally identified that the Plan could have an adverse effect on the SPA and Ramsar site due to an increase in water demand from growth in West Northamptonshire and in combination with plans for major development and growth in the Milton Keynes and South Midlands area.

Over-abstraction could, in turn, result in:

- a reduction in water levels, directly reducing habitat available to water birds and indirectly affecting them through effects on the aquatic plants, invertebrates and fish on which they feed;

- a reduction in disturbance-free areas available to water birds; and

- concentration of pollution and higher nutrient levels, with adverse effects on prey species for water birds.

The HRA recognised that the potential effects of over-abstraction are being addressed through compensation measures associated with Anglian Water’s Draft Water Resources Management Plan (WRMP) which would ensure that additional habitat is created and the water levels are seasonally secured in the key locations used by water birds, thus maintaining water quality, aquatic vegetation and diversity of prey species. Likely significant effects could not be ruled out at the Emergent JCS stage due to uncertainty as to whether the reduction in demand assumed by Anglian Water’s Draft Water Resources Management Plan would be achieved and the lack of JCS policies to limit water use by new homes.

Likely significant effects were ruled out at the Pre-Submission and Proposed Changes stages

Policy S10 of the Proposed Changes Core Strategy requires that all development maximises water efficiency and protects, conserves and enhances natural environment assets.

Policy BN7a requires that new development ensures that adequate water supply infrastructure is available and that all new housing is water efficient (minimum Level 4 water conservation standard in Code for Sustainable Homes or equivalent).

Effects of water consumption by adjacent districts taken into account by the Water Cycle Strategy and WRMP.

No likely significant effects or need for Appropriate Assessment due to the reduction in housing growth, the initial conclusions of the emerging Water Cycle Strategy and the mitigating policies included in the JCS.

A Phase 1 Water Cycle Study was undertaken on the basis of the proposed housing development included in the East Midlands Plan, being 62,125 net additional dwellings for the period 2001-2026 in the West Northants JCS area. The Phase 1 Water Cycle Study found no significant constraints to that level of growth with respect to water resources, subject to appropriate investment.

Phase 2 of the Water Cycle Study was prepared at the time of the Pre-Submission Core Strategy but was not published in time to inform the accompanying HRA.

The Phase 2 Water Cycle Study water demand forecasts are based on a combination of ONS population predictions and the housing provisions within the Pre- Submission JCS, which are used to distribute the forecast demand geographically. The Pre-Submission JCS planned for 50,150 dwellings to be delivered over the period 2001-2026. The Phase 2 Water Cycle Study found no significant constraints to delivering the development in the Pre-Submission JCS in terms of water resources, subject to all new housing development being built to a standard equivalent to Code for Sustainable Homes Level 3 (105 l/h/d), enforced though national Building Regulations or local planning policy.

Although it is now proposed that the JCS plan period be extended by three years so that it covers 2001-2029, the net additional housing it provides for is still 3,125 less than proposed in the East Midlands Plan for 2001-2026. However, this is 8,850 more dwellings than provided

Potential effect of the Proposed Changes JCS prior to mitigation

Mitigation included within the JCS

In-combination effects

HRA conclusion on effects of Proposed Changes JCS

Effects of the Proposed Main Modifications to the JCS, alone or in- combination

due to the following:

The amount of housing provided for in the Pre-Submission and Proposed Changes Joint Core Strategy for the same period (2001-2026) decreased by 23.9% and predicted housing numbers had either remained the same, were under review or had decreased in adjacent districts.
The West Northamptonshire Emerging Water Cycle Strategy was published and concluded that “Anglian Water Services (AWS)’ strategic infrastructure and resource strategic planning within the Ruthamford Water Resource Zone will support the proposed growth within the study area until 2035” [6]. A West Northamptonshire emerging Water Cycle Strategy addendum January 2011 also provided an initial conclusion that the water supply network was not a constraint to development anywhere in the plan area.
The Pre-Submission JCS adopted the water efficiency measures suggested in the HRA of the Emergent JCS, as outlined in column 2.

for by the Pre-Submission version of the JCS on which Phase 2 of the Water Cycle Study was based. The provision for jobs is also 9,500 higher for 2008-2029 than the provision in the Proposed Changes JCS for 2008-2026.

On the basis of both the Phase 1 and Phase 2 Water Cycle Studies, it is not thought that there will be water resources related issues with respect to the Proposed Main Modifications to the JCS. However, given the increase in net housing additions over that proposed in the Pre-Submission Core Strategy, there is some uncertainty over this conclusion.

Anglian Water’s WRMP covers the period 2007/08-2036/37 [7]. Its water demand assumptions are based in part on Regional Spatial Strategy (RSS) and Local Development Framework (LDF) housing targets. Given its publication date of February 2010 it is therefore assumed that the housing growth figure used for West Northamptonshire was the 62,125 net additions set out in the East Midlands Plan and reflected in the Emergent Core Strategy. The Ruthamford Water Resources Zone within which the Plan area is located is forecast by the WRMP to move into supply-demand deficit during the AMP6 period, 2015-2020. This will necessitate a basket of supply and demand management measures, emphasising the need for the Joint Core Strategy to deliver water-efficient new homes.

Joint Core Strategy Policies S10 and BN7a offer mitigation in respect of the potential impacts of over-abstraction on Rutland Water SPA and Ramsar site, although this is not as specific as the policy protection in respect of potential water supply and water level effects on Upper Nene Valley

Gravel Pits SPA and Ramsar site. However, additional assurance can be drawn from the Anglian Water WRMP [7] which states that “Following an extensive study to secure the use of Rutland Water to increase the output from the reservoir a package of habitat creation works has been implemented that will protect the integrity of the reservoir as an SPA against drawdown during a period of drought.”

Taking these mitigating factors together it is possible to conclude that there will be no adverse effect on the integrity of the European site in relation to water supply and water levels.

Upper Nene Valley Gravel Pits SPA and Ramsar site

European site information

5.7 Parts of the Upper Nene Valley Gravel Pits SPA and Ramsar site are situated within the Plan Area. The SPA stretches discontinuously from Northampton to Thrapston and has been designated on the strength of the assemblage of water birds using it during winter.

5.8 The integrity of the European site depends on maintenance of extensive reed bed with a wet base and open channels suitable for Bittern, a high water table in winter and the maintenance of varied topography and water levels as well as a continued variety of vegetation and prey species for the various bird species using the site.

5.9 The types of potential adverse effect on this site identified by previous stages of HRA are:

Loss of supporting habitat through land take.
Fragmentation of the European site from supporting habitat.
Adverse effects on water supply and water levels due to increased water demand associated with housing growth.
Reduced water quality due to increases in treated wastewater discharges associated with housing development and in contaminated surface water runoff from built surfaces.
Increased disturbance affecting bird species, either due to an increase in visitors to the site, or due to urbanisation of adjacent areas resulting in increases in light, activity and noise.
Increased pet predation associated with housing growth.

Consultation with Natural England and fieldwork prior to the Proposed Main Modifications to the JCS

5.10 The part of the SPA nearest Northampton is one of its most sensitive areas as it supports approximately 40% of the Golden Plover in the SPA. According to Natural England, the Golden Plover prefer to use the flood storage area at Clifford Hill (also known as Northampton Washlands) and are already subject to significant recreational disturbance, in particular dog walkers. Golden Plover also use arable fields near Clifford Hill for feeding. Loss of supporting habitat and recreational disturbance have been the two potential adverse effects of greatest concern to Natural England to date. As summarised in a June 2010 HRA Briefing Note [8], additional fieldwork and desk study were therefore carried out in consultation with Natural England to identify:

The numbers and species of Golden Plover, Lapwing and Wigeon at the Clifford Hill Gravel Pits.
Which areas within the Northampton South East SUE preferred option, identified through the Emergent Joint Core Strategy, are suitable feeding areas for Golden Plover. This included identifying fields which are unlikely to be used by Golden Plover, may be used by Golden Plover or are very likely to be used by Golden Plover. The area of study was the land covering the proposed Northampton South East SUE plus a 2 km buffer around it. The output of this element of the additional work was a GIS map layer that enables the identification of fields which could accommodate new development; a copy of the map is provided at Figure 5.1. It shows that approximately half of the study area provides optimal potential feeding and roosting habitat for Golden Plover (shaded red) and a large proportion of the remainder provides sub-optimal habitat (shaded amber).
How Golden Plover and Lapwing are currently affected by disturbance on the Clifford Hill Gravel Pits.
If possible, the effects of urbanisation on Golden Plover and Lapwing.

5.11 The findings of this additional work provided the basis for further discussion with Natural England to identify areas that could potentially be developed and whether the adverse effects on designated bird species could be avoided and/or mitigated, as set out in the HRA of the Pre- Submission JCS.

Figure 5.1 Quality of supporting habitat for Golden Plover to south east of Northampton [8]

Summary of development provided by the Proposed Main Modifications JCS in relation to Upper Nene Valley Gravel Pits SPA and RAMSAR site

5.12 Table 5.2 summarises the main elements of development provided for by the Proposed Main Modifications JCS in and around Northampton and its spatial relationship to the Clifford Hill Gravel Pits component of Upper Nene Valley Gravel Pits SPA and Ramsar site. This information has informed the Appropriate Assessment.

Table 5.2 Key elements of development provided for in and around Northampton

Name of development	JCS PolicyRef	Type of development	Location of development
Northampton South of Brackmills Sustainable Urban Extension (SUE)	N6	1,300 dwellings; local employment opportunities	2.3 km to south west of Clifford Hill Gravel Pits site; partially separated from European site by Brackmills area of Northampton
Northampton South SUE	N5	1,000 dwellings; local employment opportunities	4.3 km to south west of Clifford Hill Gravel Pits site; separated from European site by Northampton urban area
Northampton Upton Park SUE	N9	1,000 dwellings; local employment opportunities	6.1 km to west of Clifford Hill Gravel Pits site; separated from European site by Northampton urban area
Northampton Norwood Farm/ Upton Lodge SUE	N9A	3,500 dwellings; local employment opportunities	6.0 km to west of Clifford Hill Gravel Pits site; separated from European site by Northampton urban area
Northampton West SUE	N4	2,550 dwellings; local employment opportunities	7.6 km to north west of Clifford Hill Gravel Pits site; separated from European site by Northampton urban area
Northampton King’s Heath SUE	N7	3,000 dwellings; 10 ha employment land	4.9 km to north west of Clifford Hill Gravel Pits site; separated from European site by Northampton urban area
Northampton North of Whitehills SUE	N8	1,000 dwellings; local employment opportunities	6.0 km to north west of Clifford Hill Gravel Pits site; separated from European site by Northampton urban area
Northampton North SUE	N3	3,500 dwellings; 10 ha employment land	4.5 km to north of Clifford Hill Gravel Pits site; separated from European site by Northampton urban area
Northampton Town Centre and Central Area	N1, N2	40,500 m2 retail floorspace; 100,000 m2 office floorspace; infill housing; leisure and service development; employment development by redevelopment at existing sites and SEMLEP Northampton Waterside Enterprise Zone	Clifford Hills Gravel Pits is adjacent to the Central Area and the SEMLEP Northampton Waterside Enterprise Zone
Northampton Transport Network Improvements	N12	Variety of improvements, including to the strategic highway network	Clifford Hills Gravel Pits is adjacent to the A45 and A428

Appropriate Assessment of Proposed Main Modifications to JCS

5.13 The Appropriate Assessment of the Proposed Main Modifications to the JCS is set out in the final column of Table 5.3. It builds on the previous HRA conclusions (set out in the HRA of the Pre- Submission Core Strategy, as amended by the HRA Addendum accompanying the Proposed Changes Core Strategy) which are summarised in the first four columns of the table.

Table 5.3 Appropriate Assessment of the effects of the JCS on Upper Nene Valley Gravel Pits SPA and Ramsar Site

Potential effect of the Proposed Changes JCS prior to mitigation	Mitigation included within the JCS	In-combination effects	HRA conclusion on effects of Proposed Changes JCS	Effects of the Proposed Main Modifications to the JCS, alone or in-combination
Loss of supporting habitat
Policy N5: Northampton South SUE and Policy N6: Northampton South of Brackmills SUE have the potential to destroy areas of supporting habitat. Survey work to identify the potential for Golden Plover and Lapwing to use fields to the South East of Northampton concluded that the vast majority of the study area, including that to be developed under Polices N5 and N6, is possibly or entirely suitable as supporting habitat. With such a mobile species it is difficult to estimate what proportion of all supporting habitat used by these designated bird populations would be lost to development under Policies N5 and N6. This and other limitations of the survey led Natural England to conclude that it can only be used to direct development to less optimal land and any development proposed in the survey area will require additional survey work to determine the effect on supporting habitat.	Policy BN4 requires that all new development demonstrate through the development management process that there will be no significant adverse effects on the integrity of Upper Nene Valley Gravel Pits SPA and Ramsar site, including loss of supporting habitat.	No additional plans or projects have been identified that threaten supporting habitat in the area. This was discussed with Natural England.	Safeguards in the Plan are sufficient to ensure no adverse effect on integrity.	Screening of the Main Modifications revealed that additional housing development is proposed at Northampton South of Brackmills SUE and the area of the SUE has been extended accordingly. As previously identified at Proposed Changes stage and illustrated in Figure 5.1, the land parcels covered by the SUE provide optimal or sub- optimal supporting habitat for Golden Plover. There is therefore a potential for additional housing development of the SUE to destroy areas of land currently providing supporting habitat. This gives rise to a need for more detailed survey work as part of the development management process to determine the habitat value of the affected land parcels, in line with previous Natural England representations and the requirements of Policy BN4. Protection is afforded by Policy BN4 and the fact that these effects are more appropriately assessed at the development management stage. In this case, detailed survey work has already been carried out for the land parcels on which the SUE is proposed, as a result of an application for outline planning permission to develop an SUE at the location [9]. The survey, which was conducted after consultation with Natural England, concludes that ‘the proposed development would have no significant impact on habitats used by foraging Golden Plovers in the winter period and would not affect the conservation status or numbers of wintering Golden Plover present on the Upper Nene Valley Gravel Pits pSPA/pRamsar site.’ In light of the above, it is possible to conclude that there will be no adverse effects on site integrity in relation to loss of supporting habitat.
Fragmentationl
The HRA of the Emergent Joint Core Strategy (EJCS) originally identified the potential for fragmentation of the European site from the surrounding supporting habitat. This related to the building of new travel connections and an urban extension to the south east of Northampton (rejected option 3). These have not been included within the Proposed Changes JCS and no other policies were identified as likely to cause fragmentation.	No further measures needed. In any event, Policy BN4 requires that all new development demonstrate no significant adverse effects on the integrity of Upper Nene Valley Gravel Pits SPA and Ramsar site, including loss of supporting habitat. Additionally, Policy S10 requires development to promote the creation of GI networks, enhance biodiversity and reduce the fragmentation of habitats.	No in-combination effects.	No adverse effect on integrity due to the non- inclusion of the link road and the south east urban extension in the Proposed Changes JCS.	No likely significant effects identified by HRA screening of Proposed Main Modifications (see Appendix 1). None of the Proposed Main Modifications is judged to give rise to fragmentation of the European site with the surrounding supporting habitat.
Water supply and water levels
The 2009 HRA of the EJCS originally identified that the plan could have an adverse effect on the SPA and Ramsar site due to an increase in water demand from growth in West Northamptonshire, in combination with plans for major development and growth in the Milton Keynes and South Midlands area. The 2011 HRA of the Pre-submission Joint Core Strategy concluded that there would be no adverse effects on site integrity on the basis that: a) The amount of housing had reduced by 23.9% compared to the EJCS (the housing provision in the Proposed Changes JCS of 50,150 homes for 2001-2026 was well below the 62,125 envisaged by the EJCS). The 2009 West Northamptonshire emerging Water Cycle Strategy, which had been published since the HRA of the Emergent strategy, concluded that “AWS’s strategic infrastructure and resource strategic planning within the Ruthamford Water Resource Zone will support the proposed growth within the study area until 2035”. This was confirmed in a January 2011 Addendum Report to the Water Cycle Strategy. Since the West Northamptonshire emerging Water Cycle Strategy was based upon the original housing figures and since these had been lowered, this suggested the amount of available headroom would increase. Mitigation in Policy S10 (see next column).	Policy S10 of the Proposed Changes Core Strategy requires that all development maximises water efficiency and protects, conserves and enhances natural environment assets. Policy BN4 requires that all new development demonstrate no significant adverse effects on the integrity of Upper Nene Valley Gravel Pits SPA and Ramsar site, including due to water abstraction, either as a direct result of the development alone or in combination. Policy BN7a requires that new development ensures that adequate water supply infrastructure is available and that all new housing is water efficient (minimum Level 4 water conservation standard in Code for Sustainable Homes or equivalent). The supporting text to Policy BN7a requires that “New developments will need to have the necessary means of water supply but this must not affect the water levels at the Upper Nene Valley Gravel Pits Special Protection Area (SPA) or overall water quality”.	Effects of water consumption by adjacent districts taken into account by the Water Cycle Strategy.	No adverse effect on integrity due to the reduction in housing growth and the mitigation measures included. Whilst Policy BN4 provides sufficient protection, the wording of Policy BN7a could nevertheless be strengthened so that it is consistent with the supporting text highlighted in the preceding column.	A Phase 1 Water Cycle Study was undertaken on the basis of the proposed housing development included in the East Midlands Plan, being 62,125 net additional dwellings for the period 2001- 2026 in the West Northants JCS area. The Phase 1 Water Cycle Study found no significant constraints to that level of growth with respect to water resources and waste water treatment, subject to appropriate investment and changes to discharge consent licences. Phase 2 of the Water Cycle Study was prepared at the time of the Pre-Submission Core Strategy but was not available in time to inform its HRA. Its water demand forecasts are based on a combination of ONS population predictions and the housing provisions within the Pre- Submission JCS, which are used to distribute the forecast demand geographically. The Pre- Submission JCS planned for 50,150 dwellings to be delivered over the period 2001-2026. The Phase 2 Water Cycle Study found no significant constraints to delivering the development in the Pre-Submission JCS in terms of water resources, subject to all new housing development being built to a standard equivalent to Code for Sustainable Homes Level 3 (105 l/h/d), enforced though national Building Regulations or local planning policy. Although it is now proposed that the JCS plan period be extended by three years so that it covers the period to 2029, the net additional housing it provides for is still 3,125 less than proposed in the East Midlands Plan for 2001-2026. However, this is 8,850 more dwellings than provided for by the Pre- Submission version of the JCS on which Phase 2 of the Water Cycle Study was based. The provision for jobs is also 9,500 higher for 2008-2029 than the provision in the Proposed Changes JCS for 2008-2026. On the basis of both the Phase 1 and Phase 2 Water Cycle Studies, it is not thought that there will be water resources related issues with respect to the Proposed Main Modifications to the JCS. However, given the increase in net housing additions and provision for new jobs over that proposed in the Pre-Submission Core Strategy, and the potential issues regarding meeting WFD objectives, there is some uncertainty over this conclusion. It is judged, however, that Core Strategy Policies S10, BN4 and BN7a (and their supporting text) offer strong protection to Upper Nene Valley Gravel Pits SPA and Ramsar site in relation to potential adverse water supply and water level management effects (see column 2). This provides sufficient assurance that the JCS, as amended by the Proposed Main Modifications, will not result in an adverse effect on the integrity of the European site in relation to water supply and water levels.
Water quality
The HRA of the Emergent JCS originally identified that the Plan could have an adverse effect on the SPA and Ramsar site due to an increase in polluted surface water run-off relating to both an increase in hard standing area from growth in West Northamptonshire (in combination with plans for major development and growth in the Milton Keynes and South Midlands area) and the new link road between the A45 and the M1. This was no longer considered an issue after: a) The Pre-Submission version of the JCS removed the new travel connections and urban extension to the south east of Northampton (rejected option 3). The West Northamptonshire emerging Water Cycle Strategy concluded that no deterioration of water quality would occur downstream as a result of the growth proposed in the Northampton and associated increase in capacity at Great Billing WwTW.	No further mitigation was needed to rule out adverse effects on site integrity for the Proposed Changes JCS but in any event: Policy BN4 requires that all new development demonstrate no significant adverse effects on the integrity of Upper Nene Valley Gravel Pits SPA and Ramsar site, including due to water runoff, water abstraction or discharges from the foul drainage system either as a direct result of the development alone or in combination. Policy BN7 requires that adequate wastewater treatment capacity is available to address capacity and environmental constraints and that water quality, as far as is practicable, is protected or improved. It further requires development to uses SUDS wherever practicable to improve water quality. The supporting text to Policy BN7a requires that “New developments will need to have the necessary means of water supply but this must not affect the water levels at the Upper Nene Valley Gravel Pits Special Protection Area (SPA) or overall water quality”. Policy BN9 states that development likely to cause pollution, either individually or cumulatively, will only be permitted if measures can be implemented to minimise pollution to a level which provides a high standard of protection for environmental quality.	The Environment Agency license and control all discharges and abstractions. They have responsibilities to ensure no deterioration of water quality under the WFD. Natural England is confident there are no plans, proposals or projects identified that would interfere which the achievement of the EA’s objectives for the Nene.	No adverse effect on integrity due to the non- inclusion of the link road and the South East urban extension.	The Proposed Main Modifications increase the total amount of housing provided by the JCS by 8,850 dwellings relative to the Pre-Submission and Proposed Changes versions of the JCS. The provision for jobs is also 9,500 higher for 2008-2029 than the provision in the Proposed Changes JCS for 2008-2026. There is therefore the potential for the modifications to have an adverse effect on water quality at the European site due to increases in contaminated surface run-off and discharges from the foul drainage system. The Phase 2 Water Cycle Study did not identify significant constraints with respect to waste water treatment capacity, although it was noted that additional licences and investment in infrastructure would be required. However, the Phase 2 study did raise issues with respect to compliance with the Water Framework Directive, with regard to phosphates linked to the quality of treated wastewater discharge. Specifically, it noted that in a number of locations it is not possible to achieve good ecological status nor to prevent deterioration in the current classification with respect to phosphate, that compliance with good status is an issue even without any development, and that in most cases it is not possible to achieve good status for phosphate even if wastewater treatment works were upgraded to the best that can be achieved with current technology. These issues are likely to be exacerbated by the Proposed Main Modifications JCS because of the 8,850 additional dwellings they provide for relative to the Pre-Submission JCS as well as by the additional provision for jobs. It is judged that the water quality protection afforded by JCS Policies BN4, BN7, BN7a (including supporting text) and BN9 is strong. This provides sufficient assurance that the JCS, as amended by the Main Modifications, will not result in an adverse effect on the integrity of the European site in relation to water quality. We also note that various initiatives are underway to address phosphate levels in the River Nene, including the River Nene Partnership Project, which should provide additional mitigation.
Disturbance
The non-inclusion of the South East SUE to Northampton in the Pre- Submission JCS substantially reduced the earlier concern that the Plan would lead to an increase in visitors at the site. The non- inclusion of the transport corridor avoided earlier concerns related to traffic noise, activity and lighting. However, there was still the potential for an increase in the number of visitors from the urban extensions planned for the South, North and West of Northamptonshire although this was expected to be relatively minor in comparison to development of new homes adjacent or in easy walking distance from the site. However, as field surveys identified that Golden Plovers and Wigeon were already subject to a significant level of disturbance at the Clifford Hill Gravel Pits, and that an increase in the frequency of disturbance would have an adverse effect, additional measures were recommended to be included in the Plan to ensure no adverse effect on integrity (see next column). There was also a potential issue with the need to maintain an unobstructed line of sight for the Golden Plover for predator detection which is important while feeding, resting and roosting. Development close to habitat used by Golden Plover can reduce sight lines and therefore the habitat’s suitability for feeding and roosting.	SUE Policies N3-N9 require the inclusion of structural green space and wildlife corridors. This is in line with Natural England’s advice to provide suitable alternative natural green space (SANGS) as a part of urban extensions to meet the recreation needs of new residents and reduce the attractiveness of the European site for recreation. Policy BN4 requires that all new development demonstrates that any associated increase in recreational activity (indirect or direct) will not have a detrimental impact on the Upper Nene Valley Gravel Pits SPA and Ramsar. Any development leading to any increase in recreational activity at the European site must include necessary mitigation, including development and implementation of habitat and access management plans. The latter requirement reflects survey findings that education of visitors with regards to the site’s ornithological importance, as well as exclusion of visitors and dogs from the washlands basin could result in a reduction in the current pressures on qualifying bird species and allow an increase in visitors to be accommodated. Policy BN4 requires that new development within 250 m of the European site undertakes an assessment to demonstrate that sight lines for designated bird species will not be adversely affected. New development in this zone which is directly adjacent to existing buildings should reflect surrounding building heights.	The proposed new link between the Grand Union Canal and River Ouse, although not located within the JCS area could also cause disturbance of waterfowl and possibly roosting and feeding Golden Plover and Lapwing in winter through increasing boating traffic. However, survey work identified that activities outside of the basin rarely resulted in disturbance to the birds. Therefore, unless the additional boating traffic resulted in an increase in people entering the basin it is unlikely that this would lead to a significant increase in disturbance. Development in the areas of Wellingborough, Higham Ferrers and Rushden could increase traffic on the A45 which lies immediately adjacent to the European site. No information is available on the percentage increase in traffic that would result in a significant adverse impact on the integrity of the site. The increase in such external pressures emphasises the need for the plan to not only avoid an adverse effect but to support measures which would allow the European site to accommodate additional visitors.	The non-inclusion of the South East SUE and transport corridor, requirements to incorporate structural green space and wildlife corridors in urban extensions, as well as Policy BN4 allowed a conclusion of no adverse effect on integrity from the Plan.	The Proposed Main Modifications increase the total amount of housing provided by the JCS by 8,850 dwellings and may therefore add to existing bird disturbance at Upper Nene Valley Gravel Pits SPA / Ramsar site. The protection afforded by JCS Policy BN4 is judged sufficient to ensure no adverse effect on the integrity of the European site in relation to disturbance.
Pet predation
Earlier concerns about the potential for increased pet predation were addressed in the Pre-Submission JCS by: a) Removal of the Northampton South East SUE option and rejected option 3 which were located close to the boundary of the European site. b) A requirement in Policy BN4 that “nonew development (resulting in net gain of units) will be permitted within 900m of the potential special protection area boundary”. The 900 m buffer was removed in the Proposed Changes JCS but it was considered that this would not result in likely significant effects as the removal of the South East SUE meant that the only residential development likely to take place within this distance would be small scale and primarily within the existing residential area to the north of the European site, which is separated from the it by the river Nene and the A45.	No further measures needed.	It was not considered likely that any other plans or policies could lead to pet predation on the SPA.	No adverse effect on integrity of the European site.	No likely significant effects identified by HRA screening of Proposed Main Modifications (see Appendix 1). None of the Proposed Main Modifications is judged to give rise to an increased risk of pet predation on the European site.

Overall conclusions of the HRA for the Proposed Main Modifications

Rutland Water SPA and Ramsar site

5.14 The HRA of the Emergent JCS originally identified that the Plan could have an adverse effect on the SPA and Ramsar site due to an increase in water demand from growth in West Northamptonshire and in-combination with plans for major development and growth in the Milton Keynes and South Midlands area. However, three substantial changes occurred between the HRA of the Emergent JCS in 2009 and the HRA of the Pre-Submission JCS in 2011, as follows.

5.15 Firstly, the level of housing provided for in the Pre-Submission and Proposed Changes Joint Core Strategy for the same period (2001-2026) decreased by 23.9%. With regard to adjacent districts, predicted housing numbers had either remained the same, were under review or had decreased; there was no evidence of increasing housing numbers within adjacent districts at that stage.

5.16 Secondly, the West Northamptonshire Emerging Water Cycle Strategy was published and concluded that "Anglian Water Services (AWS)' strategic infrastructure and resource strategic planning within the Ruthamford Water Resource Zone will support the proposed growth within the study area until 2035" [6]. A January 2011 West Northamptonshire emerging Water Cycle Strategy Addendum also provided an initial conclusion that the water supply network was not a constraint to development anywhere in the plan area.

5.17 Thirdly, the Pre-Submission JCS adopted the mitigation measures suggested in the HRA of the Emergent JCS. These included the requirement within Policy S10 to maximise water efficiency and for all development to achieve a standard at least equivalent to Level 4 of the Code for Sustainable Homes. This water efficiency requirement also implements the recommendations within the West Northamptonshire Water emerging Water Cycle Strategy to ensure that all new developments (including greenfield and brownfield) are built to a minimum of Code for Sustainable Homes Level 3 (105 l/h/d), and preferably higher.

5.18 With the reduction in housing growth, the initial conclusion of the emerging Water Cycle Strategy and the proposed mitigation measures included in the plan, it was possible to conclude at the Pre- Submission and Proposed Changes stages that there would be no likely significant effects on Rutland Water SPA and Ramsar site from an increase in water demand and that the site could be removed from further consideration in the Appropriate Assessment.

5.19 As detailed in Appendix 1, HRA Screening of the Proposed Main Modifications to the JCS has highlighted the potential for likely significant effects on Rutland Water SPA and Ramsar site from the Proposed Main Modifications in respect of an increase in the number of dwellings to be provided in the Plan period and the resulting potential for adverse effects on the European site's water supply and water levels. Full Appropriate Assessment of the Proposed Main Modifications was therefore carried out, as presented in Table 5.1 and Table 5.3, and found that the additional housing and jobs growth provided for in the Plan period will not have an adverse effect on site integrity. This is because of a combination of policy protection provided within the JCS and a package of habitat creation works implemented by Anglian Water to protect the integrity of the reservoir as an SPA against drawdown during a period of drought.

Upper Nene Valley Gravel Pits SPA and Ramsar site

5.20 The HRA of the Emergent JCS identified that the Plan could have an adverse effect on the SPA and Ramsar site due to the proximity of development and quantum of development proposed in Northampton.

5.21 The quantum of development reduced between the Emergent and Pre-Submission versions of the JCS. Also, the South East SUE option, which was in close proximity to the European site, was not included in the Pre-Submission JCS. Concerns remained, however, that some of the Pre- Submission JCS policies could result in likely significant effects, particularly on Golden Plover and Lapwing which feed on land surrounding the SPA, leading to the full Appropriate Assessment summarised in the first four columns of Table 5.3. Table 5.3 also reflects the minor changes between the Pre-Submission and Proposed Changes versions of the JCS, where relevant.

5.22 As set out in Appendix 1, HRA screening of the Main Modifications to the JCS highlighted the potential for likely significant effects on Upper Nene Valley Gravel Pits SPA and Ramsar site from the Main Modifications in respect of an increase in the number of dwellings to be provided in the Plan period. Full Appropriate Assessment of the Main Modifications was therefore carried out, as presented in the final column of Table 5.3 with the following results.

In respect of the potential for loss of supporting habitat for the European site's designated Golden Plover interest, extension of Northampton South of Brackmills SUE will not have an adverse effect on site integrity. This is because of policy protection within the JCS, the fact that potential effects of developing in this SUE are more appropriately assessed at the development management stage and the existence of detailed survey work which shows that the land that would be lost to development does not play a significant role as supporting habitat for Golden Plover.
In respect of the potential for adverse effects on the European site's water supply and water levels, the assessment found that the additional housing and new jobs provided for in the Plan period will not have an adverse effect on site integrity. This is because of the very strong policy protection provided within the JCS.
In respect of the potential for adverse effects on the European site's water quality, the assessment found that the additional housing and new jobs provided for in the Plan period and increased traffic on the A45 will not have an adverse effect on site integrity. This is because of the very strong policy protection provided within the JCS.
In respect of the potential for disturbance of the European site's bird interest from increased visitor numbers and obstruction of lines of sight for the Golden Plover for predator detection, the assessment found that the additional housing provided for in the Plan period will not have an adverse effect on site integrity. This is because of the strong policy protection provided within the JCS.

Overall conclusion and recommendations

5.23 HRA Screening of the Proposed Main Modifications to the JCS revealed that likely significant effects could be ruled out on Rutland Water SPA and Ramsar site and on Upper Nene Valley Gravel Pits SPA and Ramsar site. However, more detailed Appropriate Assessment of these effects did not identify any adverse effects on the integrity of either of these European sites. No impact avoidance measures put forward by the preceding HRA work remain outstanding. The overall conclusion of the HRA of the Pre-Submission JCS, as amended by the HRA Addendum for the Proposed Changes to the JCS, therefore remains valid and it is therefore possible to conclude that the JCS, as amended by the Proposed Main Modifications, will not result in adverse effects on the integrity of any European site.

5.24 Although not necessary to support this conclusion, LUC supports the following recommendation of the previous HRA work and recommends that it be incorporated within the modifications to the JCS:

Policy BN7a could be strengthened so that it is consistent with the supporting text which directly references the Upper Nene Valley Gravel Pit SPA “New developments will need to have the necessary means of water supply but this must not affect the water levels at the Upper Nene Valley Gravel Pits Special Protection Area (SPA) or overall water quality”.

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